Dove & Love Beauty & Planet Are Lying to Your Face About Being “Natural”
Unilever slapped a “93% Naturally Derived” seal on your shampoo while the second and third ingredients by weight were industrial synthetic chemicals. A federal class action complaint explains exactly how they did it — and why they knew it was a lie.
TL;DR
- Unilever — the multinational corporation that owns Dove and Love Beauty & Planet — sold shampoos, conditioners, body washes, and skin creams with labels claiming they were “90% to 97% Naturally Derived.”
- Those claims are false. A federal class action complaint filed April 25, 2025 (Case 3:25-cv-03660-JCS) alleges the products are, in reality, only approximately 80–85% naturally derived — and that key synthetic chemicals, like sodium laureth sulfate and behentrimonium chloride, appear as the second and third ingredients by weight.
- Unilever’s “natural” math is based on ISO 16128, a private industry standard created without public input that costs $400 to read — and which its own authors explicitly stated was “not intended for use in product labeling.”
- Under this same standard, aspartame could be labeled “100% naturally derived.” Hydrogenated vegetable oil — banned from “natural” food labeling — would qualify as “~99% naturally derived.” Even dioxins (toxic byproducts of burning wood) could score “90% natural origin.”
- Plaintiffs Jeffrey Kent, Monica Burrola, and Nitaya McGee purchased these products at Walgreens, Safeway, Target, and grocery stores in California, relying on the “Naturally Derived” seals on packaging. They are now suing on behalf of all California purchasers dating back to April 25, 2021.
- Unilever was formally notified of the deceptive claims in writing: Plaintiff Burrola sent a demand letter on November 11, 2024; Plaintiff Kent sent one on February 6, 2025. Unilever did not fix it.
- The lawsuit demands compensatory damages, punitive damages, restitution, and injunctive relief under California’s Consumer Legal Remedies Act, False Advertising Law, and Unfair Competition Law — plus a federal fraud claim.
- The complaint covers dozens of products across Love Beauty & Planet and Dove Men + Care lines, including at least 14 shampoo/conditioner scents, 6 body washes, 12 body creams, and 12 Dove Men + Care variants.
The $400 Secret: How Unilever Turned Industrial Chemistry Into a “Natural” Seal
When you pick up a bottle of Love Beauty & Planet Vegan Silk Protein Shampoo at Target and see “93% NATURALLY DERIVED” stamped in a bold circle seal on the front label, surrounded by illustrated branches and botanical imagery, your brain does exactly what Unilever designed it to do: it concludes you are buying something close to nature. Something plant-based. Something that didn’t come out of a chemical reactor. That conclusion is wrong, and Unilever knew it was wrong.
According to the federal class action complaint filed April 25, 2025 in the Northern District of California, Unilever’s “Naturally Derived” percentage claims are calculated using ISO 16128, a proprietary standard created by the British Standards Institute (BSI) — a private, for-profit institution, not a government agency, not a public health body, and certainly not any entity with consumer protection as its mandate. The BSI developed ISO 16128 without any public comment process, relying entirely on cosmetic industry scientists. Consumer advocates were not involved.
Here is how the standard works, in plain terms: instead of measuring how much of your shampoo actually came out of a plant or a mineral spring, ISO 16128 compares the molecular weight of the atoms in an industrial chemical to the molecular weight of whatever natural starting material was used in its synthesis. If a significant portion of the mass of the final synthetic molecule can be traced back to a natural starting point — say, coconut oil — then the entire resulting industrial chemical gets classified as “naturally derived,” even if it was created through a multi-step industrial chemical process involving chloroacetic acid, petrochemical solvents, and industrial fermentation.
The complaint offers a blunt example: cocamidopropyl betaine, a synthetic surfactant that appears as one of the top ingredients by weight in Dove Men + Care products, sounds like it might be natural because of the “coc-” prefix suggesting coconut. The complaint clarifies this directly: it is made through a two-step industrial process, beginning with the reaction of dimethylaminopropylamine with fatty acids from coconut or palm kernel oil, followed by the use of chloroacetic acid to form the final product. Under ISO 16128, a large portion of this industrial chemical’s mass traces back to coconut, so it qualifies as “naturally derived.” By any standard a regular person would apply, it is a synthetic chemical. It requires an industrial facility to produce. You cannot find it in a coconut.
The complaint also illustrates the absurdity of the standard with three telling comparisons. Aspartame, the artificial sweetener no one would describe as “natural,” could technically be labeled “100% naturally derived” under ISO 16128 because its starting materials (two amino acids and methanol) all occur in nature. Hydrogenated vegetable oils, which cannot be marketed as “natural” on food packaging under existing standards, would qualify as approximately “99% natural origin” in cosmetics under ISO 16128 — because the added hydrogen atoms represent only a tiny fraction of the molecule’s total mass. And dioxins, toxic materials produced when wood burns, could score “90% natural origin” because the bulk of their molecular mass comes from wood, which is a natural material.
If you wanted to read the ISO 16128 standard yourself and understand how Unilever is calculating these numbers, you cannot. The BSI forbids public distribution. To purchase both volumes of the standard, you would need to spend nearly $400. And even if you did, the first page of the standard explicitly states: “Neither ISO 16128-1 nor this document addresses product communication (e.g. claims and labelling).” The standard’s own creators told manufacturers not to use it for labeling. Unilever used it for labeling anyway.
“In other words, the BSI told Defendant and other third parties that the standard was not suitable for consumer communications — advertisements, labels, and marketing. Defendant thus had actual or constructive knowledge that ISO 16128 was likely to deceive and/or confuse consumers.”This is the engine of the scam. A private industry group creates a mathematical formula that lets synthetic industrial chemicals count as “natural.” They lock it behind a $400 paywall. They warn manufacturers it was never meant for product labels. Unilever prints it in giant type on the front of 50+ product lines anyway, surrounds it with botanical imagery, and charges a price premium to health-conscious consumers who are specifically looking for natural ingredients and who studies confirm do not spend extra time verifying label claims because they trust them.
Unilever’s label claims vs. estimated actual naturally derived content per the complaint. The gap between the two bars represents the deception premium consumers paid for.
The Non-Financial Ledger: What This Lie Cost Real People
There is a financial injury at the center of this case — the price premium Unilever extracted from consumers who paid more for “natural” products than they would have paid had they known the truth. But the dollar figure doesn’t fully account for what was actually taken from the people named in this lawsuit, or the millions of consumers like them who bought these products in good faith. The theft here has dimensions that don’t fit cleanly into a damages calculation.
Consider Jeffrey Kent, a San Francisco resident who purchased Dove Men + Care Eucalyptus and Birch 2-in-1 Shampoo and Conditioner from Walgreens and Safeway as recently as August 2024. The complaint describes a man who actively looks for natural ingredients before making purchase decisions. That’s not a casual preference — that’s a deliberate value system. He reads labels. He compares products. He uses ingredient content as a genuine buying criterion, not just a vibe. Unilever knew exactly who Jeffrey Kent was. The “90% Naturally Derived” claim stamped in a bold circle near the top of the front label was engineered specifically to intercept consumers like him at the moment of decision. It worked. He trusted the number. He had no reason not to. The complaint is direct: “He did not have any reason to believe that the Products were less than 90% naturally derived as claimed on the label.” He was targeted because he cared, and he was deceived because he trusted. The complaint makes clear he now describes Unilever’s conduct as a “bait-and-switch tactic.” He is still uncertain whether any future Unilever product he might buy will be truthfully labeled.
Monica Burrola of Rio Linda, Sacramento County, purchased Love Beauty & Planet Vegan Silk Protein Shampoo and Conditioner from a grocery store in North Highlands, California, around spring 2024. She relied on the “93% Naturally Derived” and “97% Naturally Derived” claims on the labels — labels that even now, according to the complaint, she finds “misleading and confusing.” The back-label definition Unilever included — “naturally derived, meaning it’s unchanged from nature or, after some processing, keeps over 50% of its original structure” — did not clarify matters. It could not clarify matters, because it was specifically written to obscure the truth without technically lying. It describes the ISO 16128 framework in consumer-friendly language without ever disclosing that the resulting “naturally derived” chemicals were created in industrial facilities using chloroacetic acid, hydrogenation, and multi-step synthesis. Burrola, like most people, lacked the chemistry background to decode that language. She was supposed to lack that background. The system was designed for her to lack it. What was taken from her was not just the price differential on a bottle of shampoo — it was her ability to make an informed choice about what went into her body and what her dollars supported.
Nitaya McGee of Riverside, California, purchased Love Beauty & Planet 3-in-1 Avocado Oil, Mango and Vitamin E “97% Naturally Derived” Shampoo from a Target in June 2023. The complaint describes the same pattern: she relied on the label, she had no way to verify it, and even reading the back-label disclaimer after the fact still left her unable to determine the truth. The complaint reveals a particularly telling detail in her case: the products she bought have ingredient lists showing that of the twenty ingredients in the LBP Avocado Oil, Mango, and Vitamin E Shampoo, thirteen are synthetic — including five of the top six ingredients by weight. The avocado oil and mango that appeared in the product name and dominated the front label imagery were minor components, not predominant ones. McGee’s complaint notes that she “continues to be interested in skin and cosmetic products comprised of natural and naturally derived ingredients” but “does not know whether any Defendant Products she may purchase in the future will be subject to the same false advertising.” The theft of trust is ongoing. The anxiety about future purchases — whether any “natural” claim can be believed — is a concrete harm Unilever created and continues to perpetuate.
Zoom out from the three named plaintiffs, and the picture is larger and darker. The complaint establishes that the natural beauty market was generating $7 billion globally in annual sales by 2007 and growing at roughly 9% per year. The consumer base driving that growth is specifically health-conscious and environmentally-conscious. Studies cited in the complaint confirm these consumers “were willing to pay more” for natural products. Seventy percent of respondents in one survey said they would pay a premium for a cosmetic with a natural ingredient. These are not naive shoppers making impulsive decisions. They are people who prioritize their health and the planet, who are willing to make financial sacrifices for those priorities — and who are, precisely because of those priorities, extremely vulnerable to the kind of manipulative labeling Unilever deployed. Unilever did not stumble into a gray area. It made a calculated decision to extract a premium from the most values-driven segment of the beauty market.
The complaint also documents an institutional betrayal layered on top of the individual one. Studies show that health and environmentally-conscious consumers “did not spend more time and effort than others on comparing alternative purchase options.” They trust the label. They do not, in normal circumstances, pay $400 to obtain a private British standards document, decode chemical formulas, and calculate natural origin indices. The system relies on that trust. Unilever used that trust as a profit mechanism. And when Plaintiff Burrola sent a formal demand letter on November 11, 2024, and Plaintiff Kent sent one on February 6, 2025, Unilever did not fix the labels. It did not notify similarly situated customers. It did not provide any remedy. It received the letters and continued selling the products. That is not an oversight. That is a business decision.
“Defendant knew that the Products it sold were not comprised of the advertised proportions of naturally derived ingredients, and that its advertising materials were false and deceptive. Despite knowing this, Defendant refused and failed to change the labels, remove the false representations, or otherwise inform Plaintiffs, those similarly situated and/or the general public of the Products’ true composition.”Legal Receipts: What the Complaint Actually Says, Word for Word
The following are direct quotations and specific factual statements from the class action complaint filed April 25, 2025 in Case 3:25-cv-03660-JCS. These are the receipts. Every blockquote below is either a verbatim passage or a precisely cited factual allegation from the source document.
“In truth, most of the ingredients in the Products are synthetic, not natural. They do not originate in nature and are not derived naturally. Rather, they are of industrial-origin. Accordingly, the Products are only approximately 80-85% naturally derived ingredients. As such, the ‘% Naturally Derived’ claims are false.”
Complaint, ¶5, Case 3:25-cv-03660-JCS
“Defendant falsely and misleadingly refers to synthetic, industrially-manufactured chemicals as ‘naturally derived’ by assigning them a ‘% naturally derived’ value based on percentage of the synthetic molecule, by mass, that was present in a naturally derived starting material. In other words, Defendant mischaracterizes industrial chemicals as ‘Naturally Derived’ in order to ‘greenwash’ the Products and make them seem safer and more environmentally friendly.”
Complaint, ¶63, Case 3:25-cv-03660-JCS
“Neither ISO 16128-1 nor this document [i.e., ISO 16128-2] addresses product communication (e.g. claims and labelling), human safety, environmental safety, socio-economic considerations (e.g. fair trade), characteristics of packaging materials or regulatory requirements applicable for cosmetics.”
ISO 16128, Volume 2, quoted verbatim in Complaint ¶68, Case 3:25-cv-03660-JCS — this is the standard Unilever used for its “Naturally Derived” labels
“It is inherently problematic for Defendant to use a standard that explicitly states it is not addressing consumer-facing product claims and labelling for those purposes.”
Complaint, ¶68, Case 3:25-cv-03660-JCS
“Even if an average consumer could obtain the ISO 16128 standard (by paying fees of over $400 to the British Standards Institute), they would not understand it, because it is complicated and written for chemists.”
Complaint, ¶8, Case 3:25-cv-03660-JCS
“ISO 16128 is not a government standard, nor even a publicly agreed to standard. The BSI created ISO 16128 without any public comment. Based on information on the ISO web site, it appears that ISO 16128 was designed solely by cosmetic industry scientists, without involvement of any consumer advocates or persons familiar with consumer advertising.”
Complaint, ¶72, Case 3:25-cv-03660-JCS
“For example, of the twenty (20) ingredients listed for the Dove Men + Care Eucalyptus and Birch 2-in-1 Shampoo and Conditioner, fourteen (14) are industrially-produced chemicals that most consumers would not identify as ‘natural’ or ‘naturally derived,’ including one (citric acid) produced using industrial fermentation processes. One additional ingredient (‘fragrance’) is of ambiguous origin, though most consumer product fragrances are industrially-produced. Only water, sodium chloride, eucalyptus leaf oil and Betula Alba (i.e., birch) Leaf Extract are unequivocally natural in origin.”
Complaint, ¶58, Case 3:25-cv-03660-JCS
“Of the fourteen (14) ingredients listed for the LBP Silk Protein Conditioner, ten (10) are synthetic, including three of the top five by weight. Of the twenty (20) ingredients listed for the LBP Avocado Oil, Mango, and Vitamin E Shampoo, thirteen (13) are synthetic, including five of the top six by weight.”
Complaint, ¶58, Case 3:25-cv-03660-JCS
“Consider aspartame. It is an artificial sweetener, in the sense that it is entirely man-made and does not occur in nature. But it is potentially 100% ‘natural origin’ under ISO 16128, because all the starting materials used to make it (two amino acids and methanol) are naturally-occurring compounds. But most ordinary consumers would not view aspartame as natural or ‘100% naturally derived.’ This underscores how misleading ISO 16128 is when used in advertising, as Defendant’s Product labels do.”
Complaint, ¶73, Case 3:25-cv-03660-JCS
“Even dioxins, toxic materials produced as byproducts when burning wood, could be categorized as ‘90% natural origin,’ since the bulk of the mass of the dioxins are from wood, which is a natural material. Again, this demonstrates how ISO 16128 falsely and misleadingly characterizes synthetic compounds as primarily ‘naturally derived.'”
Complaint, ¶75, Case 3:25-cv-03660-JCS
“In many cases, Defendant’s claims are based on the specious assumption that merely using a plant as the initial source of carbon content makes the resulting synthetic chemical environmentally friendly. This assumption is false because many of the ingredients (e.g., palm oil) begin as plants grown in environmentally damaging ways. While these ingredients come from plants, the monoculture plantations where such plants are grown are often made by clear-cutting rain forests and other natural habitats, resulting in substantial environmental degradation.”
Complaint, ¶87, Case 3:25-cv-03660-JCS
“Defendant’s concealment of the true characteristics of the Products was material to Plaintiffs and Class members. Had they known the truth, Plaintiffs and the Class members would not have purchased the Products, or would have paid significantly less for them.”
Complaint, ¶128, Case 3:25-cv-03660-JCS
“Defendant’s conduct as described herein was willful and malicious and was designed to maximize Defendant’s profits even though Defendant knew that it would cause loss and harm to Plaintiffs and those similarly situated.”
Complaint, ¶119, Case 3:25-cv-03660-JCS
“Even where Defendant has discontinued certain products and/or removed the ‘X% naturally derived’ claim for a given Product, it has simultaneously introduced new products making the same false and misleading claims.”
Complaint, ¶143, Case 3:25-cv-03660-JCS
“Greenwashing refers to ‘a set of deceptive marketing practices in which an entity publicly misrepresents or exaggerates the positive environmental impact or attributes of a product[.]’ . . . [The] practice of greenwashing also affects ‘the way consumers buy cosmetic and personal products.’ . . . [I]t is used to describe products that have ‘natural’ labeling ‘but actually contain chemicals[.]'”
McGinnity v. The Procter & Gamble Company, No. 22-15080 (9th Cir. 2022) (J. Gould, concurring), quoted in Complaint ¶82, Case 3:25-cv-03660-JCS
“[T]he back label of Love Beauty & Planet Plant-Based Vanilla Body Wash states: ‘92% of our formula is naturally derived, meaning it’s unchanged from nature or keeps over 50% of its original structure after some processing. This includes water and ingredients from plant, mineral and fermentation sources.'”
Complaint, ¶33, Case 3:25-cv-03660-JCS — this is the “disclosure” Unilever used to claim consumers were informed
“The SmartLabel sites further note that the ingredient descriptions are ‘provided by Dove.'”
Complaint, ¶51, Case 3:25-cv-03660-JCS — meaning Dove itself labels its own synthetic ingredients as “naturally derived” in the third-party app consumers use to check product safety
Societal Impact Mapping: The Real Cost of Calling Industrial Chemicals “Natural”
Environmental Degradation
One of the core reasons consumers buy products labeled “natural” or “naturally derived” is environmental. The complaint cites academic research confirming that consumers associate natural cosmetics with “environmental conservation, minimization of polluting, responsible usage of non-renewable resources, and preservation of fauna and species.” When Unilever tells those consumers its products are “90-97% Naturally Derived,” it is making an implicit environmental promise: that these products were sourced and produced in ways that respect the planet. That promise is false.
The complaint directly addresses this contradiction in paragraph 87, focusing on palm oil — one of the plant-based starting materials used to create Unilever’s synthetic “naturally derived” ingredients. Palm oil is frequently sourced from monoculture plantations created by clear-cutting rainforests and other natural habitats. The complaint states this plainly: “While these ingredients come from plants, the monoculture plantations where such plants are grown are often made by clear-cutting rain forests and other natural habitats, resulting in substantial environmental degradation.” Under ISO 16128’s framework, the palm oil derivatives in Unilever’s products qualify as “naturally derived” because the palm is a plant. The rainforest that was bulldozed to grow that palm does not factor into the calculation at all.
The complaint also identifies that there is “no guarantee those plants are grown using organic farming methods, as opposed to using pesticides and other environmentally-damaging chemicals.” Consumers who buy “naturally derived” products to reduce their environmental footprint may be funding exactly the kind of pesticide-intensive monoculture agriculture they were trying to avoid. Unilever’s label gave them no way to know this. ISO 16128 gave Unilever no obligation to disclose it. The standard explicitly does not address environmental safety — that exclusion is written directly into the document Unilever used as its authority.
The FTC’s Green Guides, which the complaint references as directly applicable guidance, state that it is deceptive to misrepresent — directly or indirectly — that a product is “made with renewable materials” without sufficient specificity. The complaint argues that Unilever’s “naturally derived” claims run afoul of this guidance because they fail to identify the specific basis for the natural content claim and instead imply a broad environmental benefit that the products’ actual production methods do not support. The synthetic chemicals in these products were produced using industrial chemical processes that consume energy, generate byproducts, and may involve toxic manufacturing inputs — none of which are captured in the ISO 16128 “natural origin” score that ends up on the label as a percentage.
Public Health
The other half of why consumers buy “natural” products is personal health. The complaint establishes this clearly: consumers who prefer natural beauty products hold two material beliefs — that natural products are safer and/or better for their bodies, and that natural products are better for the environment. When a person chooses a shampoo labeled “97% Naturally Derived” over a competing product with no such claim, they are making a health choice. They believe they are reducing their exposure to synthetic industrial chemicals. That belief is the specific belief Unilever designed the label to create. And it is false.
The actual ingredient lists tell the true story. The complaint details that in the Dove Men + Care Eucalyptus and Birch 2-in-1 Shampoo and Conditioner, sodium laureth sulfate and behentrimonium chloride appear as two of the top three ingredients by weight. In standard shampoo formulations, those two ingredients alone constitute roughly 15% of the product’s formula. These are industrial surfactants. The full list of synthetic ingredients in this single product also includes sodium benzoate, dimethiconol, carbomer, TEA dodecylbenzenesulfonate, PPG-9, disodium EDTA, propylene glycol, and linalool. Fourteen of the product’s twenty listed ingredients are industrially-produced chemicals that, per the complaint, “most consumers would not identify as ‘natural’ or ‘naturally derived.'”
The complaint further identifies that substances like cocamidopropyl betaine — a synthetic surfactant present in multiple products — are produced through industrial processes involving chloroacetic acid and dimethylaminopropylamine. These are not ingredients derived from nature in any practical sense that a consumer would recognize. The complaint makes the point explicitly: “despite sometimes using coconut oil as a starting material, there is nothing natural about it.” Consumers who believe they are minimizing their exposure to synthetic industrial chemicals on their skin and scalp, who rely on a “97% Naturally Derived” label to make that determination, are not getting the product they believe they are buying. The health choice they made was based on false information engineered and distributed by Unilever.
Compounding this is the SmartLabel app, which Unilever points consumers to for detailed ingredient information. The complaint reveals that SmartLabel describes specific ingredients as “naturally derived” without explaining or defining that term — leaving consumers to apply its common meaning. And it notes explicitly that the ingredient descriptions displayed in SmartLabel are “provided by Dove.” The app that is supposed to be an independent tool for ingredient transparency is, in this context, another channel through which Unilever repeats its own false classifications to consumers specifically seeking deeper health information about what they are putting on their bodies.
Economic Inequality
The natural beauty market’s price premium is not distributed equally across society. Consumers who specifically seek out natural products and are willing to pay more for them are, as the complaint establishes through academic research, health-conscious and environmentally-conscious shoppers who place high importance on ingredient sourcing. They are paying extra, repeatedly, because they care about their health and the planet. When that premium is extracted through deception, it functions as a financial penalty applied to precisely the consumers who were trying hardest to make responsible choices.
The complaint calculates harm as “the difference between the price consumers paid for the Products and the price they would have paid but for Defendant’s misrepresentations.” This is the price premium — the amount by which a bottle of shampoo labeled “97% Naturally Derived” was sold above what a comparable product without that claim would have fetched. Multiply that premium across millions of transactions spanning multiple years (the class period runs from April 25, 2021 to the present), across dozens of products in the Love Beauty & Planet and Dove Men + Care lines sold at Walgreens, Safeway, Target, Walmart, Amazon, and grocery chains nationwide, and the total wealth transfer from health-conscious consumers to Unilever is substantial — the complaint establishes jurisdiction on the basis that the amount in controversy exceeds $5,000,000 in California alone.
The deception also produces a specific competitive distortion in the market. Unilever’s false “naturally derived” claims give it an unfair advantage over competitors who either genuinely use natural ingredients (at higher production cost) or who truthfully label their synthetic ingredients as synthetic. The California Business and Professions Code claims in the complaint specifically identify this: Unilever’s “aforementioned practices . . . constitute unlawful competition and provide an unlawful advantage over Defendant’s competitors as well as injury to the general public.” Companies doing the harder, more expensive work of actually formulating products with a high proportion of genuinely natural ingredients are undercut in the market by a multinational corporation that simply reclassifies industrial chemicals as “natural” using a private, $400 standard written for chemists.
The ISO 16128 standard’s inaccessibility compounds the economic inequality angle. Wealthy or highly-educated consumers with chemistry backgrounds, institutional resources, or $400 to spend on a British standards document might eventually work through the math and realize what Unilever is doing. The complaint is explicit that ordinary consumers cannot: they “lack the expertise and/or information necessary to determine the veracity of the claims.” The product of Unilever’s scheme is a market where scientific and economic literacy determines who gets deceived. Those with the most resources to verify claims escape the premium; those without them pay it indefinitely. That is the design, even if it is not articulated as such in any boardroom.
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